ML20207S840

Notification of 840702 Meeting W/Licensee in Bethesda,Md to Discuss Util Submittal on Piping & Supports.List of Attendees,Meeting Agenda & Related Documentation Encl

ML20207S840
Person / Time
Site:	Diablo Canyon
Issue date:	06/26/1984
From:	Schierling H Office of Nuclear Reactor Regulation
To:	Knighton G Office of Nuclear Reactor Regulation
Shared Package
ML17325B782	List: IA-84-741, Forwards Inputs to Sser 24,including Staff Evaluation of 840202 Petition Filed by Govt Accountability Project Inst for Policy Studies & Updated Info on Allegations 39 & 45. SALP Input Encl ML20204G482 ML20204G589 ML20204G603 ML20204G606 ML20204G646 ML20204G660 ML20204G695 ML20204G701 ML20207S747 ML20207S758 ML20207S787 ML20207S803 ML20207S831 ML20207S840 ML20207S856 ML20207S871 ML20207S884 ML20244D033
References
FOIA-84-741, FOIA-84-742 NUDOCS 8703200319
Download: ML20207S840 (30)

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Occket No. 50-275 Ohk MEMORANDUM FOR: G. Knighton, Chief Licensing Branch No. 3 Division of Licensing -

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H. Schierling, Project Manager Licensing Branch No. 3

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8:30 am I g g NU A LOCATION: Room P-118 Phillips Buildi 2 h e gc,g Bethesda, Maryland d PURPOSE:

Discussion of PG&E submittal on Piping and Supports L. % dG Note: This meeting will be transcribed. -

Uk@G.n PARTICIPANTS: NRC

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R. Vollmer, J. P. Knight, R. Bosnak, T. Sullivan, M. Hartzman, I. Yin, H. Schierling, NRC Consultants Licensee ,

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. AGEtOA July 2,1984 bHC Meeting 1.- Opening NRC Remarks - NRC

11. Opening PGondE Remarks - C. A: Moneotis lil. PGondE Presentations A) Status of Piping / Supports License Condition (including item I of 6/20 NRC Letter)- L. E. Shipley B) Assessment of IDVP Reviews for Piping / Supports (item 2 of 6/20-NRC Letter) .lDVP C) Review of Onsite/HQ Engineering Activities (item 3 of 6/20 NRC Letter) - H. B. Friend /R. Omon D)

Review of Onsite/HQ GA Activities (ltem 3 of 6/20 NRC Letter)-

M. J. Jocobson (Project QA) and S. M. Skidmore (PGondE QA)

IV. Closing Comments - NRC l

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PGan:E OPENING REMARKS G. A. Maneatis Good morning, I'm George Monectis, Executive Vice President of Focilities and Electric Resources Development for Pacific Gas and Electric Company. With me this morning are Howard Friend of Bechtel, the Diablo Canyon Project Completion Manager, Bruce Norton, our licensing attorney, other members of the Diablo Canyon Project, and representatives from the IDVP.

We are pleased today to respond to any questions you may have regarding information we have recently submitted to the Staff on matters relating to the issuance of a full power license for Diablo Canyon.

As you are aware, we provided you with our initial responses to the low power license condition regarding piping and piping supports earlier this month.

Subsequently, 'we otso responded to your June 20th request for additional information on piping and supports.

To facilitate our discussion today, we have prepared a brief presentation on recent Project activities related to piping and piping support issues. Larry Shipley of the Diablo Canyon Project will review the status of our efforts to achieve full compliance with the low power license condition related to piping.

Dr. Cloud of the Independent Design Verification Program will discuss the programmatic aspects and conclusions of the IDVP piping and piping support reviews. Howard Friend will describe the recent changes in the design authority and responsibilities of the Onsite Project Engineering Group. He will be followed by Bob Oman, Assistant Project Engineer for Systems, who will describe how onsite and home office engineering activities will be conducted as a result of the recent changes. Finally, Mike Jacobson, Project Quality Assurance Engineer and Steve Skidmore, PGondE's Monoger of Ovality Assurance, will review the quality programs applicable to this work.

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We are also prepared to oddress any questions you may have regarding our previous submittals or our presentations today.

We hope the discussions today will provide the Staff the information they will require to issue their Safety Evaluation Reports in early July.

With that, I'll turn the meeting over the Larry Shipley.

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STATUS OF PIPING / SUPPORTS LICENSE COfOlTION (including item I of 6/20 PftC Letter)

L. E. Shipley Thank you, George.

My discussion today will focus on the 7 items in the License Condition with particular attention given to items 2 and 3. I will be glad to answer any questions related to oreos that are not covered in sufficient detail.

We have prepared and submitted during early June responses to License Condition items I through 7. We belive that the Staff's concerns have been fully ,

oddressed on: ltem I, small bore Strudi Review; Item 4, thermal gaps, item 5, hot piping walkdowns, item 6; DP/TC program; and item 7, technical issues. A final report that will close the minor open items that were contained in the previous submittals for items I and 6 is currently under preparation and will be transmitted to the Staff tomorrow, July 3,1984.

Licensing Condition items 2 and 3 have been the subject of considerable discussion with the Stoff and the NRC's Audit Team over the past 2 weeks. The criteria for selection of proximity restraints was resolved with the Stoff during on NRC audit in Son Francisco on June 21,1984.

SLIDE This slide depicts that proximity criteria os it applies to l' arge and small bore piping. DISCUSS SLIDE.

Review of small bore rigids/ snubbers adjacent to anchors will exclude decoupled branch connections for piping qualified by span rules (simplified analysis). The 1

review and identification of all snubbers /rigids for all piping ossociated with this revised criteria has now been completed. The necessary analysis to demonstrate piping quellfications has likewise been completed. A walkdown to measure the I

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. gaps at all rigids identified by the IOD proximity review is well underway. Any additional shimming required as a result of these reviews will be completed on or about July 13,1984, but certainly before ascension above 5% power.

1 In our June 11, 1984 submittal concerning License Conditions item I, we identified 15 of the more complex small bore Strudi analyses that had not yet been completed. Review of these last 15 are now complete and they all have been shown to meet the licensing requirements. Thus, in total, we have completed the review of aj computer analyzed small bore pipe supports, as required by License Condition item I, and no physical modifications have resulted from these additional reviews.

In our submittal of June I,1984, concerning License Condition item 6, we identified on in-process review of piping analysis and several pipe supports. This review is now complete and piping and supports have shown to be qualified in the as-built condition. This information will be provided in the final report we will submit tomorrow.

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i REVIEW OF ONSITE/HQ ENGiffERING ACTIVITIES R. Omon The purpose of my presentation is to discuss the new responsibilities and authorities of onsite engineering and home office engineering in the future, and to describe the present engineering activities at OPEG and the design control measures in effect during the current transition period.

In order to clearly define the new role of onsite engineering for the future, a revision to Project Engineer's Instruction (PEI) 9, which defines the scope and responsibilities of the OPEG organization has been developed. In developing this revised instru,ction, the basic philosophy has been that support engineering activities which must of necessity be done at the jobsite will continue to be done there by OPEG. Design Engineering octivities which do not have to be done at the jobsite will be done by home office engineering.

1) The project recognizes the benefit and need for a continuing engineering presence onsite to be involved with tasks such as: (a) field walkdowns to confirm the installed configuration of particular aspects of the plant, (b) assessment of the feasibility of construction of specific new design items, (c) Interfacing with the construction and startup organizations to clarify engineering's understanding of their problems and the formulation of responsive and occeptable solutions to them.

These types of tasks are being defined as " Support Engineering Activities."

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2) In contrast, "Desion Engineering Activities" are being defined os "a technical activity which modifies or issues design documents. Design documents are engineering calculations, design change notices, specificottons, and I

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, drawings. Engineering opproval of a Fleid Change Request is also considered a design engineering octvity.

3) Furthermore, in the revision to the procedure the distinction is being made between engineering activities which offect safety-related systems, structures and components, and those which are involved with the non i safety-related items.

4) The revised scope of OPEG outhority is then defined in the following terms:  !

(a) OPEG is not authorized to perform "desian engineering activities" for " safety-related" systems, structures and components. OPEG may perform

" support engineering octivities" for " safety-related" systems, structures and components. For example i

this would authorize field verification and feasibility studies, but would not include the

, issvonce of design documents such as calculations or DCN's.

(b) OPEG may perform both "desian engineering activities" and " support engineering activities" for

. "non safety-related" systems, structures and components.

In order to ovoid confusion and to more clearly detall the specific i

implementation of this revised scope of outhority in the procedure itself, a 5-

! page matrix has been prepared as on ottochment to PEl-9. The matrix identifies oli safety-related engineering activities previously within the OPEG scope of work and defines them in terms of the revised OPEG scope as:

l) continue within OPEG scope of responsibility.

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2) Design engineering responsibily transferred to SFHO.

3) OPEG support of design engineering octivities to continue but final review and approval by SFHO.

The work items are organized in the matrix for both Unit I and Unit 2 by engineering discipline. The following are some examples of the details of this matrix:

o in the piping discipline OPEG will continue to do:

heotup and power ascension piping walkdowns feasibility studies for new pipe supports ,

SFHO will do:

i small bore stress analysis and pipe support design calculations snubber reduction program resolution /opproval of FCRs i

• It is expected that the revised Project Engineer's Instruction will be issued formally this week and it will have the concurrence of the Project Completion

Manager.

l l would like now to discuss OPEG engineering activities during the current i fronsition period.

As a result of the Project Completion Monoger memorandom dated June 14,1984 -

rescinding OPEG's design engineering outhority, steps were immediately taken to implement the directive.

l. Instructions by the Engineering Manager were given to the Onsite Project Engineer to discontinue all design engineering activities.

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2. A meeting of all Unit i engineering group supervisors was held in SFHO to onnounce the change in OPEG design engineering outhority, and each ECS was directed to contoct their respective discipline representative in OPEG to assure SFHO engineering personnel were henceforth approving all design engineering activities.

3. Since June 14, many engineedng activities previously accomplished by individual discipline engineers within OPEG have continued.

These include field walkdowns, construction feasibility checks, clarificotton of construction and startup problems, formulation of solutions to such problems, initioting oppropriate DCRs, and initiating engineering calculations for proposed design changes. However, since June 14 no engineering design documents have been formally approved by on OPEG lead discipline engineer or issued by the OPE or AOPE's. This applies to design calculations, design change notices, specifications, drawings, and engineering occeptance of as-built drawings. Approval and issuance of such engineering documents hos occurred under the direct review and authority of SFHO design engineering since June 14.

Therefore, during the period since June 14, in fact on additional level of review has been achieved for engineering activities initiated by OPEG.

l l 4. As a further action, on June 22, the Unit i Project Engineer instructed the Onsite Project Engineer to transmit all Unit I small bore stress and pipe support calculations to SFHO by the 29th of June. This has now I

been occomplished and no further Unit I small bore stress or pipe support calculations will be initiated onsite.

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, in summary, the project has octed promptly to implement the Project Completion Monoger's directive to rescind OPEG design engineering authority.

A revised project instruction will be issued this week which defines the new 4 scope of responsibilities and authorities of onsite engineering and home office I

engineering. During the interim tronsition period, steps have been token to assure that approval and issuance of aJll engineering documents did occur under the direct review and authority of SFHO engineering.

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A separate but related topic to this discussion concerns the Pipe Support Design -

Tolerance Clarification Program. As previously reported, the PSDTC program as defined in Project Engineer's Instruction 12 was discontinued effective June 8, 1984. All Unit I pipe support design changes made subsequent to that date have been occomplished by the Design Change Notice process of Engineering Manual Procedure 3.60N.

in order to facilitate field resolution of pipe support related construction problems on Unit 2 in the future, a new Field Change Request (FCR) procedure 4

has been instituted urider Project Engineer's Instruction 19. This FCR program is essentially the same as that successfully used on a number of other Bechtel 3

projects and will apply to all deviations proposed by Construction from pipe support designs issued by Engineering where the proposed deviations are beyond

approved installation tolerances. Construction will initiate requests for such deviation on an FCR form and submit them to Engineering for review and approval. The engineering approval of the FCR will include Justification for 1

acceptance. Where a calculation is required to verify the odequacy of the

proposed change, the calculation will be completed in accordance with l Engineering Manual Procedure 3.3 prior to approval of the FCR. The engineering f opproval of an FCR will be indicated by the signature of the responsible engineer, the group supervisor, and the Project Engineer.

in the case of deviations proposed by Construction which do not alter the i

functional design characteristics of the pipe support or which are minor design drawing clarifications, General Construction Lead Discipline Engineers can authorize in-process work to continue on an "at-risk" basis for up to five days i l S

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while Engineering opproval of the FCR is being obtained. The authorization will be in writing and will be included in the pipe support work package before the work con proceed. This in-process change authority will expire and work so authorized will cease if Engineering approval is not received in five days.

For all pipe support modifications for Unit I or Unit 2, the pipe support os-built drawings will continue to include any modifications authorized by a previous PSDTC or on FCR such that no deviations will exist between the os-built drawing and any modifications authorized in the field. The final engineering acceptance of the installed condition will continue to be the final engineering review, checking, and approval of the os-built pipe support drawing.

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REVIEW OF ONSITE/HQ ENGitEERING ACTIVITIES H. B. Friend Thank you This morning I would like to spend a few minutes providing the background on our recent action regarding the engineering design authority that had been delegated to the On Site Project Engineering Group.

You will recall that the modification work on Unit I was done under the provisions of the Operating License for the unit. Even though the License was suspended in 1981, PGondE felt that it was important to retain in place all the requirements of the license; in particular those aspects that involved Operating Department knowledge and control of changes to the facility. In order to maintain control during the modification program, close coordination between the Operating Group and the Engineering Group was required. Therefore it was important that on engineering presence be involved at the jobsite to coordinate with the Operating Group.

The type of work that was being done on Unit I also called for on engineering design presence at the jobsite. The need to modify several thousand supports in an already constructed facility with the attendent major physical coordination activities mandated that some engineering design authority be vested at the jobsite.

It has also been demonstrated historically that small piping and supports are

! most effectively designed when the engineering group is physically located at the jobsite .

For these several reasons, OPEG had been established and had been delegated certain engineering design authority.

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By the spring of this year, we had effectively completed the work on Unit I, we achieved Criticality on April 29 and completed Low Pewer Testing on May 23.

Also our work on Unit 2 was well advanced with all Class I piping supports and modifications issued by May ll. The important coordination activities of the OPEG were essentially complete.

In this some time frame, we had also been concerned that, during several audits both by our Quality Groups and the NRC, programmatic and technical concerns about the work of OPEG had been noted.

While the observed deficiencies posed no safety problems, it was decided on June 14 that it would be appropriate to revoke the Design Engineering authority of the On Site Project Engineering Group and return the authority to the Horne Office Engineering Group.

This action was taken for the following reasons:

to render mont any continuing perception that work being performed by OPEG was not in full compliance with Project and Corporate OA Programs. Although extensive corrective actions had already been token and the adequacy of the hardware had been demonstrated, we wanted to erase any lingering concerns that might exist.

to begin to convert the role of engineering from designing for construction and modification to one of supporting on operating facility.

to centralize the engineering uctivities supporting the operating facility in the Home Office for more effective management.

Our objective is to provide a smooth transition from our onsite project

' engineering design activities to Home Office engineering activities in support of an operating unit.

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i One of the most important considerations in making this change was that the transition proceed smoothly and that no item "foll through the crocks".

To tell you in deto:1 how we are accomplishing this change without incident I would like to turn this meeting over to Bob Omon. Bob is one of our APE's and is very knowledgeable of the subject. Earlier on the project, Bob was in charge of the OPEG and has o unique perspective of both ends of this change.

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REVIEW OF ONSITE/HQ OA ACTIVITIES l M. J. W Introduction My discussion will focus on item 3 of the NRC letter which deals with Ovality Assurance matters. I will be addressing the Project GA Program in place at the Home Office and at OPEG, specifically, I will address the elements of that Program that provide us assurance that work formerly performed at OPEG will be carried out in conformance with quality assurance requirements. The elements I wish to discuss are the programmatic odequacy of the DCP OA Program and actions that have been taken to strengthen implementation where appropriate both in the Home Office and at OPEG. We believe that the DCP QA Program is effective and we are strongly committed to implementing that Program, as well as pursuing beneficial improvements.

Procram The DCP OA Program is programmatically sound. It is based on the standard Bechtel QA Program as described in the NRC - approved Bechtel Topical Report BO-TOP-l Rev. 3A. Organizational differences were defined in a OA Program Description for the Diablo Canyon Project which in turn was submitted to and approved by the NRC Staff. The commitments of the QA Program Description and the policies of the DCP Nuclear Quality Assurance Manual that carry out these commitments remain the basis for an effective QA Program. The procedural changes we have made have been predominantly at the second and third level of implementing procedures, where each level deals with increasingly detailed aspects of implementation.

The DCP OA Program was developed and written for the design activities at the Home Office and, by extension, to OPEG which was delegated a portion of the design work.

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i The DCP QA Program is therefore fully compatible with new design work i ossigned to the Home Office. In addition, other factors give us confidence that the portion of OPEG work transferred to the Home Office will be properly controlled, i

o Work performed at the Home Office is closer to Project Monogement and is a necessary focal point for monogement attention.

o Communication and coordination between Engineering and -

the Quality Groups is easier and more direct.

o Piping Group procedures used by OPEG were originally prepared for the engineering work of Project Headquarters, and are well suited to the work flow there.

I would now like to address the specific areas listed under item 3 of the NRC letter, identifying actions taken or programs in place which assure that (1) work retained within OPEG and (2) work transferred to the Home Office will be ,

performed, In occordance with QA requirements. The improvements included in these progroms apply equally to the Home office and OPEG. '

ltem (o): Indoctrination and Trainino We m, ode several changes to procedures to clarify and strengthen controls in this oreo:

1) More restrictions were introduced such that engineers must have received training in engineering design control

' procedures prior to their originating, checking or approving any design documents pertolning to safety-i related systems, structures or comonents. A previous j

' reference to a 30 day maximum period for receiving trotning was dropped in factor of this more restrictive approoch.

2) The method for Identifying newly assigned personnel that 4

i would require trotning was strengthened. Quality Engineering is notified of all newly assigned personnel.

Quality Engineering then immediately holds trotning i

sessions for these new personnel, only offer these sessions l ore they allowed to initiate or check design documents.

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Actions to assure implementation of trotning include the following:

1) A complete review of trotning records was performed to assure that all Engineers had received training. For accountability, on improved data base was developed showing all Engineers currently or formerly assigned to the Project, olong with the dates they octually received trotning.

2) Quality Assurance and Quality Engineering personnel have been assigned to assure that trotning records are kept current and that new orrivals are trained.

3) A recent PCondE GA oudit and a monitoring activity by Project GA both confirmed that implementation of training in the Engineering Manual procedures was odequate.

Item (b): Document Control improvements have been made to avoid use of unauthorized documents to perform piping design work as addressed in our letter of June 26, 1984. In summary, we focused attention on the importonce of complying with document control procedures and on the responsibility of each individual to update monvols correctly and return ocknowledgement forms. We changed our procedures to require supervisors to periodicolly review the monvols in their group, and to require supervisors to discuss and document the content of procedure changes with engineers in their group to be sure everyone is aware of changes and how they are to be implemented.

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A complete review of all Piping monvols was performed by Engineering to assure they were up-to-date.

2) The distribution of Piping monvois is being reassessed to minimize "porflat distribution" monvols that are more difficult to control. At present we have a large number of controlled monvols assigned at the Home Office assuring that procedures are ovalloble in the work area.,

At OPEG the distribution of Piping monvols hos been revised to ensure adequate ovallobi!Ity to design personnel in each work arco.

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3) An additional program is being placed into effect on a trial basis to provide a frequent and periodic verification of the content of all controlled manuals. Monuols will be recolled, checked, and then returned to the manual '

holder.

4) Audits and monitoring activities of monval control have been increased, item (c) - Preliminary Deslon Data and Desion Interfoces Our program for controlling the use of preliminary design data was described in our June 26, 1984 letter. Preliminary design dato used in calculations must be specifically identified and specificolly resolved through a revision to the calculation package. Calculation logs provide o tracking mechanism to assure preliminary dato used hos been closed. Design information provided verbolly (including by telephone) must be confirmed in writing.

Project GA Audits of the proporation of calculations specifically include reviewing the resolution of preliminary dato. Recent audits of OPEG, Unit i Home Office, and Unit 2 Home Office found implementation in this area to be acceptable.

Design interfaces between OPEG ond the Home Office are being redefined in PEl-9 os previously discussed by Mr. Oman.

Item (d)- Timeliness of Project Re=~mses The DCP QA Program requirements relating to timeliness of response to safety ,

concerns and audit findings described in our June 26, 1984 letter ore equally applicable to work at the Home Office. Procedures require prompt resolution of Discreponey Reports and Nonconformance Reports. Timely progress of resolution of Discrepancy Reports is monitored by both,Ouolity Engineering and Project Quellty Assurance.

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Timely response to audit findings is also being stressed. For each Project Audit finding, recommended actions and a completion schedule are reviewed with the audited organization and agreed to prior to conclusion of the audit. This  :

practice allows corrective measures to begin immediately. At OPEG, on '

odditional report entitled "QA Open items Summary" is issued on a weekly basis '

to provide a visible status of each open Quality Audit Finding, including the scheduled dotes for response, opproval and closure.  !

Responses to open Project audit findings are current. Any exceptions that may occur are identified on the Delinquent Open items Report which is provided to Monogement as a vehicle to focus management attention on obtaining response.

The Quality Hotline, which is o method for employees to freely express concerns,

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has been implemented in the Home Office os well as of OPEG. Timely feedback l on resolution of any matters identified is being emphasized.

item (e)- QA Procram Audits DCP Project audits are planned in advance to ensure that all aspects of design control are implemented. A Moster Audit Plan is prepared to identify all  ;

required audit areas. A schedule is developed identifying those audit areas which ore to be audited during each quarter, including the schedule for of least a year in advance. This planning is used to provide full coverage of Project Activities i on a schedule that is consistent with the Project schedule for the activities being audited. Project Audits are supplemented by Project GA monitoring activities (documented quellty reviews similar to audits) and by Management Audits performed by Bechtel Son Francisco Power Division Quality Assurance. ,

Responses to Project Audit findings are evoluoted for acceptability prior to closure. Project GA reviews the response to assure that the recommended remedlol, investigative, and corrective actions (or acceptable alternates) have i been performed. ,

Sottsfactory implementation of these actions is verified by l

} Project GA, and Justificotton for closure is documented on the Quellty Audit i Finding form.

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The Project Quality Assurance Engineer reviews the closure actions taken and reissues the Audit Report when he is in ogreement that all findings have been satisfoctorily closed. As indicated in our letter of April 4,1984, DCP oudit findings related to OPEG were not closed prior to corrective action taking place, item (h) concerning the Tolerance Clarificotton Program was previously oddressed by Mr. Oman.

In summary, we believe that the DCP OA Program and the actions I have described, provide effective GA control in these oreos.

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PACIFIC GAS APO ELECTRIC COMPANY'S QUALITY ASSURANCE COMMENTS FOR THE F#tC MEETING S. Skidmore JULY 2,1984 Introduction Thank you, George.

Like Mr. Jacobsen, my comments will also oddress the specific areas listed under item 3 of the NRC letter and focus on the Corporate OA Program in place to assure that work retained within OPEG or transferred to Project Headquarters -

will be carried out in conformance with applicable quality assurance requirements.

While Mr. Jacobson spoke of some of the projects actions, I'll be describing some of the broader policy octions the PGandE OA department is taking in response to these same issues.

Item 3a: With Records to Personnel Indoctrination and Traininct in mid-1983, the training group in the PGondE Ovality Assurance Department embarked on a training enhancement project to develop and implement a Company Ovality Assurance orientation program for all nuclear work related to the design, construction, and operation of Diablo Canyon Power Plant. The first phase of 4he project included developing a Quality Assurance orientation film titled, "Doing it Right the First Time." This film is introduced by George Moneatis, Executive Vice President, FERO, and was completed in December I983.

Beginning in early February 1984 and continuing through April 1984, more than 6,500 workers associated with the Diablo Canyon Project saw the film during scheduled orientation sessions. These sessions included experienced training to discuss the film and its contents, which includes the quality hotline program.

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In mid-June 1984, the Quality Assurance orientation film was presented to PGandE's officers. Our plans include a program to make certain all riew. workers, will receive this orientation.' 3everal members of the NRC staff h.:ve .,een the film, and comments have been positive.

'l We have a Ovality Assurance Training Program Development Projee.t. This project includes elements of quality training for General Office end site personnel. -

Examples of Indoctrination include o Auditor training "

o Quality Assurance Program o Documents containing Ovality Assurance commitments o Computer systems for statistici, c.xf analysis o Procurement principles and supplier quollficotlon We are evaluating the feasibil.ity of INPO ce-tifica'lon for the training pregram.

This effort is presently scheduled for full Irnplementation by April 1985 ond will include methods for mcInf alning skills.

• 1 Item 3b and item 3c: With reongs to document control and desion control: '

In furtherance of Corporate goals and as on enhancement to the existing PCondE' -

Ouality Assurance Progrcm, PGandE submitted o complete revision to Chapter 17 of the Dloblo Canyon FSAR in June 1983. After on extensive review of this revision by Region V ogainst the Standard Review Plan, the revised Chnpfer 17 was approved on Decembe'r 20,1983.

In anticipation of this o;9roval, work was started by an Iritradepartmental Ovality Task Force to develop a chorter governing task force activities and work Instructions to control the progress of the Quality Assurance enhancement '

program. The involved departments include Ovality Assurance, Engineering, Nuclear Power Generation, Station Construction, Engineering Computer 2

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Applicottons,JPI'onning and Research, Materials, and Law. This enhancement program will assure that a current and effective quality program is in pioce which is consistent with federal regulations, industry standards, and meets q Corporate Quality Assurance commitments, os defined in our revised Chapter 17. .

Furthermore, at the completion of its primary task, the Quality Task Force will raras;n as a stonding committee to assist in the timely incorporation of new or

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( revised federal regulations and commitments into the Quality Assurance f

4 Program. The Quality Assurance Department will review departmental program

! and programmatic procedure changes prior to implementation.

L As a parallel effort to the Ovality Assurance enhancement project, the Quality

Assurance Department has been reviewing the major Diablo Canyon contractors' quality programs for consistency and compliance with the revised Chapter 17. -

The results of these reviews are being incorporated into revisions to their quality programs. .

In addition, two procedures in particular have been revised to improve the control of information contained in 29 controlled quality manuals. Quality Assurance Manuel Procedure 4.2, " Control of Quality Manuals for in,structions and Procedures", was issued recently to all departments, including Engineering.

l This procedure provides a uniform and consistent opproach to the control of i

a quality manuals. In addition, Quality Assurance Manual procedure ll.1, " Quality

! / Assurance Audits," has been revised to provide clearer procedural control of the details of corrective actions to Identify the handling of generic implications of audit findings.

i ltem 3d: With Record to Timely Closure of OA Audit Findinast In. August 1983, o quality problem report (OPR) tracking system was developed in the Quality Assurance Department to oddress timely closure of Quality Assurance audit findings and departmental and contractor quality problem reports. This system, developed to demonstrate compliance with commitments made to the NRC, prioritizes outstanding quality problem reports and establishes estimeted completion dates. The objective is to assure that corrective action on r 3

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OPRs, identlNed as being necessary to close prior to mode changes at Diablo Ccnyon's Unit I, would be occomplished. This system provides senior management with a centrol point of information so that timely closure is readily

[' opparent. Results are issued weekly or, in some cases, daily assuring timely flow of OPR information to monogement. Initially, this program required some 3,200 GPRs to be prioritized and completion dates established. In all cases, OPRs prioritized to be closed before operational mode changes were closed. This computerized reporting system has been effective and will continue in use for both Units I and 2 at Diablo Canyon.

The 1983 trend analysis report for Diablo Canyon developed by the PGondE Quality Assurance Department identified that the time required to resolve quality problems and verify the results and corrective actions decreased in 1983 os compared with previous experience. In addition, the average time required by all deportments to close nonconformance reports and open item reports decreased in 1983 compared to 1982. The overage time required by PGandE QuoMty Assurance to verify corrective action of NCRs decreased in 1983 over 1982.

l Item 3e: With Reacrds to the Conduct of OA Audits:

1 A computerized quality commitments monogement dato base is being developed to allow PGand to promptly demonstrate conformance to NRC requirements and to provide Quality Assurance codits with a computer generated list of quality commitments to be covered in programmatih audits.

l A systemmatic oudit plan is being developed to assure that aH Tec'hnical Specifications (TS) requirements, including all Individual TS 'line items, are l oddressed at least once every three years. This program will involve a comprehensive series of detailed audits covering all portions of the TS and is

, being established in occordance with guidelines recommended by the NRC.

(These guidelines have been recommended by the NRC's Division tof Quality Assurance, Safeguards, and Inspection Programs and endorsed in their correspondence with the NRC's Region 111).

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Conclusions:

As the Monoger of Corporate Quality Assurance, I am confident that the quality programs in place and the quality enhancement projects underway. comply with our quality commitments to the NRC.

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I. Yin's Comments on

.PG&E Ltr. 4/27/84 License Condition 2.C.(11) Item No.

and PG&E Ltr. DCL-84

-164 Enclosure No. Comments

1. Completion Review of all S/B Piping None

2. Rigid / Rigid & Rigid / Anchor in 1. Provide justification that piping close proximities. 2-inch and less should be excluded from review.

2. Address measures taken to evaluate-the 9 supports w/ limited ,

accessibility.

3. Is the 5 0 criteria including Z configuration? -

3. Snubber and rigid restraint 1. Provide bases for 5 D and 3 0

. interaction. criteria.

2. DCP should .use specific manu-facturer's test data for dead band + load actuation displacement as snubber functionability acceptance criteria.

3. Define snubber functionability conditions.

4. Provide justification that piping 2" and less should-be excluded from review.

5. Are the 5 D and 3 D criteria including Z configuration?

4. Thermal gap within rigid None restraints.

5. Main Steam hot walkdown 1. License Condition should include inspection. FW.

2. Provide piping system isometric drawings to NRC. Circle all locations where verification is planned.

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3. How the program is going to be able to address the staff's piping and structure interference concerns?

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6. DPs & Quick Fixes 1. The 8/10/82 cutoff date is (PSDTC) unacceptable. Effective implementation of DP procedures should be evaluated.

2. Staff will not comment on DCP's

" Quick Fix" evaluation at this time. Additional allegations on the issue will be factored into the staff.'s review to determine the adequacy of the DCP bresen-tation. ,

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